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For further volumes:
http://www.springer.com/series/7360
Emerging Topics in Ecotoxicology
Principles, Approaches and Perspectives
Volume 4
Series Editor
Lee R. Shugart
L.R. Shugart and Associates, Oak Ridge, TN, USA
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Bryan W. Brooks Duane B. HuggettEditors
Human Pharmaceuticalsin the Environment
Current and Future Perspectives
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Editors
Bryan W. BrooksBaylor UniversityWaco, Texas, USA
Duane B. HuggettUniversity of North TexasDenton, Texas, USA
ISSN 1868-1344 ISSN 1868-1352 (electronic)ISBN 978-1-4614-3419-1 ISBN 978-1-4614-3473-3 (eBook)
DOI 10.1007/978-1-4614-3473-3Springer New York Heidelberg Dordrecht London
Library of Congress Control Number: 201293197
© Springer Science+Business Media, LLC 2012All rights reserved. This work may not be translated or copied in whole or in part without the writtenpermission of the publisher (Springer Science+Business Media, LLC, 233 Spring Street, New York,NY 10013, USA), except for brief excerpts in connection with reviews or scholarly analysis. Use inconnection with any form of information storage and retrieval, electronic adaptation, computer software,or by similar or dissimilar methodology now known or hereafter developed is forbidden.The use in this publication of trade names, trademarks, service marks, and similar terms, even if they
are not identified as such, is not to be taken as an expression of opinion as to whether or not they aresubject to proprietary rights.
Printed on acid-free paper
Springer is part of Springer Science+Business Media (www.springer.com)
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v
Perspectives on Human Pharmaceuticals in the Environment ................... 1
Bryan W. Brooks, Jason P. Berninger, Alejandro J. Ramirez,
and Duane B. Huggett
Environmental Risk Assessment for Human Pharmaceuticals:
The Current State of International Regulations .......................................... 17
Jürg Oliver Straub and Thomas H. Hutchinson
Regulation of Pharmaceuticals in the Environment: The USA .................. 49
Emily A. McVey
Environmental Fate of Human Pharmaceuticals ......................................... 63
Alistair B.A. Boxall and Jon F. Ericson
Environmental Comparative Pharmacology: Theory
and Application ............................................................................................... 85
Lina Gunnarsson, Erik Kristiansson, and D.G. Joakim Larsson
A Look Backwards at Environmental Risk Assessment:
An Approach to Reconstructing Ecological Exposures ............................... 109
David Lattier, James M. Lazorchak, Florence Fulk, and Mitchell Kostich
Considerations and Criteria for the Incorporation of
Mechanistic Sublethal Endpoints into Environmental
Risk Assessment for Biologically Active Compounds .................................. 139
Richard A. Brain and Bryan W. Brooks
Human Health Risk Assessment for Pharmaceuticals in the
Environment: Existing Practice, Uncertainty, and Future Directions ....... 167
E. Spencer Williams and Bryan W. Brooks
Contents
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vi Contents
Wastewater and Drinking Water Treatment Technologies ......................... 225
Daniel Gerrity and Shane Snyder
Pharmaceutical Take Back Programs ........................................................... 257
Kati I. Stoddard and Duane B. Huggett
Appendix A. Take Back Program Case Studies ........................................... 287
Index ................................................................................................................. 297
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vii
Jason P. Berninger Department of Environmental Science, Center for Reservoir
and Aquatic Systems Research, Institute of Biomedical Studies, Baylor University,
Waco, TX 76798, USA
Office of Research and Development, National Health and Environmental Effects
Research Laboratory, U.S. Environmental Protection Agency, Duluth, MN 55804, USA
Alistair B.A. Boxall Environment Department, University of York, Heslington,
York YO10 5DD, UK
Richard A. Brain Ecological Risk Assessment, Syngenta Crop Protection LLC,
Greensboro, NC 27409, USA
Bryan W. Brooks Department of Environmental Science, Center for Reservoir
and Aquatic Systems Research, Institute of Biomedical Studies, Baylor University,
Waco, TX 76798, USA
Jon F. Ericson Pfizer Global Research and Development, Worldwide PDM,
Environmental Sciences, MS: 8118A-2026, Groton, CT 06340, USA
Florence Fulk National Exposure Research Laboratory, Ecological ExposureResearch Division, US Environmental Protection Agency, Office of Research and
Development, Cincinnati, OH 45268, USA
Daniel Gerrity Water Quality Research and Development Center, Southern
Nevada Water Authority, River Mountain Water Treatment Facility, Henderson,
NV 89015, USA
Lina Gunnarsson Department of Neuroscience and Physiology, Institute of
Neuroscience and Physiology, The Sahlgrenska Academy, University of Gothenburg,
405 30 Göteborg, Sweden
Duane B. Huggett Department of Biological Sciences, University of North Texas,
Denton, TX 76203, USA
Contributors
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viii Contributors
Thomas H. Hutchinson CEFAS Weymouth Laboratory, Centre for Environment,
Fisheries and Aquaculture Sciences, Weymouth, Dorset DT4 8UB, UK
Mitchell Kostich National Exposure Research Laboratory, Ecological Exposure
Research Division, US Environmental Protection Agency, Office of Research andDevelopment, Cincinnati, OH 45268, USA
Erik Kristiansson Department of Neuroscience and Physiology, Institute of
Neuroscience and Physiology, The Sahlgrenska Academy, University of Gothenburg,
405 30 Göteborg, Sweden
Department of Zoology, University of Gothenburg, 405 30 Göteborg, Sweden
D.G. Joakim Larsson Department of Neuroscience and Physiology, Institute of
Neuroscience and Physiology, The Sahlgrenska Academy, University of Gothenburg,
405 30 Göteborg, Sweden
David Lattier National Exposure Research Laboratory, Ecological Exposure
Research Division, US Environmental Protection Agency, Office of Research and
Development, Cincinnati, OH 45268, USA
James M. Lazorchak National Exposure Research Laboratory, Ecological
Exposure Research Division, US Environmental Protection Agency, Office of
Research and Development, Cincinnati, OH 45268, USA
Emily A. McVey Office of Pharmaceutical Science, Center for Drug Evaluation
and Research, U.S. Food and Drug Administration, Silver Spring, MD 20993,
USA
WIL Research, 5203DL ’s-Hertogenbosch, The Netherlands
Alejandro J. Ramirez Mass Spectrometry Center, Mass Spectrometry Core
Facility, Baylor University, Baylor Sciences Building, Waco, TX 76798, USA
Shane Snyder Chemical and Environmental Engineering, University of Arizona,
Tucson, AZ 85721, USA
Jürg Oliver Straub F.Hoffmann-La Roche Ltd, Group SHE, LSM 49/2.033,Basle CH-4070, Switzerland
Kati I. Stoddard Department of Biological Sciences, University of North Texas,
Denton, TX 76203, USA
E. Spencer Williams Department of Environmental Science, Institute of
Biomedical Studies, Center for Reservoir and Aquatic Systems Research, Baylor
University, Waco, TX 76798-7266, USA
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1B.W. Brooks and D.B. Huggett (eds.), Human Pharmaceuticals in the Environment:
Current and Future Perspectives, Emerging Topics in Ecotoxicology 4,
DOI 10.1007/978-1-4614-3473-3_1, © Springer Science+Business Media, LLC 2012
Background
Human interaction with the environment remains one of the most pervasive facets
of modern society. Whereas the anthropocene is characterized by rapid popula-
tion growth, unprecedented global trade and digital communications, energy
security, natural resource scarcities, climatic changes and environmental quality,
emerging diseases and public health, biodiversity and habitat modifications are
routinely touted by the popular press as they canvas global political agendas and
scholarly endeavors. With a concentration of human populations in urban areas
B.W. Brooks (*)
Department of Environmental Science, Center for Reservoir and Aquatic Systems Research,
Institute of Biomedical Studies, Baylor University, One Bear Place, #97266,
Waco, TX 76798, USA
e-mail: [email protected]
J.P. Berninger
Department of Environmental Science, Center for Reservoir and Aquatic Systems Research,Institute of Biomedical Studies, Baylor University, One Bear Place, #97266,
Waco, TX 76798, USA
National Health and Environmental Effects Research Laboratory, National Research Council
Research Associates Program, Office of Research and Development, U.S. Environmental
Protection Agency, 6201 Congdon Boulevard, Duluth, MN 55804, USA
e-mail: [email protected]
A.J. Ramirez
Mass Spectrometry Center, Mass Spectrometry Core Facility, Baylor University,
Baylor Sciences Building, One Bear Place, #97046, Waco, TX 76798, USA
e-mail: [email protected]. Huggett
Department of Biological Sciences, University of North Texas,
1155 Union Circle, #305220, Denton, TX 76203, USA
e-mail: [email protected]
Perspectives on Human Pharmaceuticals
in the Environment
Bryan W. Brooks, Jason P. Berninger, Alejandro J. Ramirez,
and Duane B. Huggett
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2 B.W. Brooks et al.
unlike any other time in history, the coming decades will be defined by “A New
Normal,” as proposed by Postel [ 1 ], where the interplay among sustainable
human activities and natural resource management will inherently determine the
regional fates of human societies.
In recent years, few topics have captured the public’s attention like the pres-
ence of human pharmaceuticals in environment. Fish on Prozac [ 2, 3 ]. Male fish
becoming female [ 4, 5 ]? Drugs found in drinking water [ 6, 7 ]. India’s drug
problem [ 8 ]. Chances are you have seen these headlines or read related reports.
Pharmaceuticals and trace levels of other contaminants (e.g., antibacterial agents,
flame retardants, perfluorinated surfactants, harmful algal toxins) are increasingly
reported in freshwater and coastal ecosystems. In the developed world, many of
these chemicals are released at very low levels (e.g., parts per trillion) from waste-
water effluent discharges to surface and groundwaters. But why were citizens so
engaged by stories about fish on Prozac [ 3 ] and drugs in drinking water [ 7 ]?Because pharmacotherapy is now entrenched in everyday life, a realization that
common drugs were found in the water we drink or the fish we eat likely produces
a boomerang effect, where our daily reliance on well-accepted therapies was con-
cretely linked in a new way with their potential consequences to the natural world.
On an increasingly urban planet, pharmaceutical residues and traces of other
contaminants of emerging concern represent signals of the rapidly urbanizing
water cycle and harbingers of the “New Normal.”
Over the past 2 decades the implications of endocrine disruption and modula-
tion have permeated public consciousness, scientific inquiry, regulatory frame-works, and management decisions in the environmental and biomedical sciences.
Publication of Colburn, Dumanoski, and Myers’ “Our Stolen Future [ 9 ],” which
is often referred to as the second coming of Rachel Carson’s “Silent Spring [ 10 ],”
stimulated the public, scientific, and regulatory attention given to endocrine dis-
ruptors and ultimately influenced the environmental studies of human pharma-
ceuticals [ 11 ]. For example, human reproductive developmental perturbations
elicited by the estrogenic human pharmaceutical diethylstilbestrol and feminiza-
tion of male fish exposed to municipal effluent discharges represent examples of
causal relationships among endocrine active substances and biologically importantadverse outcomes [ 12 ].
In the late 1990s, research in the area of endocrine disruption was taking off,
particularly to identify constituents of effluents or other environmental matrices that
were potentially responsible for endocrine perturbations in wildlife and humans.
Because many xenoestrogens are present in effluent discharges, initial investiga-
tions in the UK employed toxicity identification evaluation studies to fractionate
and identify causative components of the complex mixtures inherent with effluents
[ 13 ]. At the same time in the USA, Arcand-Hoy et al. [ 14 ] highlighted the impor-
tance of considering human estrogen agonist and veterinary androgen agonist phar-maceuticals as potential causative toxicants from point and nonpoint source
effluents. Also in 1998, two of the first review papers on pharmaceuticals in the
environment, by Halling-Sorensen et al. [ 15 ] and Ternes [ 16 ], appeared in the litera-
ture. In 1999, another review paper, by Daughton and Ternes [ 17 ], considered
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3Perspectives on Human Pharmaceuticals in the Environment
Pharmaceuticals and Personal Care Products (PPCP) in the environment and by
doing so coined the PPCP acronym, which remains pervasive. Subsequently, a pre-
cipitous number of workshops, symposia, special meetings, and publications related
to pharmaceuticals in the environment have occurred. For example, Fig. 1 describescitation frequencies of just the Halling-Sorensen et al. [ 15 ], Ternes [ 16 ], and
Daughton and Ternes [ 17 ] papers as surrogates for the trajectory of scientific inquiry
in this important area of environmental science and public health.
Some of the most important developments related to pharmaceuticals in the envi-
ronment included special issues of Toxicology Letters in 2002 and 2003, Pellston
workshops by the Society of Environmental Toxicology and Chemistry (SETAC) on
human pharmaceuticals (in 2003 [ 18 ]) and veterinary medicines (in 2007 [ 19 ]),
formation of the SETAC Pharmaceuticals Advisory Group (in 2005; http://www.
setac.org/node/34 ) and the Water Environment Federation’s MicroconstituentsCommunity of Practice ( http://www.wef.org ), International Conferences on the
Occurrence, Fate, Effects, and Analysis of Emerging Contaminants in the
Environment (e.g., htpp://www.EmCon2011.com ), the International Water
Association’s MicroPol conferences (e.g., htpp://www.micropol2011.org ), and a
special issue of Environmental Toxicology and Chemistry entitled “Pharmaceuticals
and Personal Care Products in the Environment” in 2009. Following an editorial by
Brooks et al. [ 20 ] entitled “Pharmaceuticals and Personal Care Products: Research
Needs for the Next Decade,” an international workshop entitled “Effects of
Pharmaceuticals and Personal Care Products in the Environment: What are the BigQuestions?” was held by Health Canada/SETAC in April 2011 [ 21 ]. In 2012, the
SETAC Pharmaceutical Advisory Group is planning another Pellston conference on
antimicrobial resistance, which represents a major threat to global public health.
Though the information in this timely area continues to rapidly expand, it appears
Year
1998 2000 2002 2004 2006 2008 2010
R e l a t i v e C u m u l a t i v e F r e q u e n c y o f C i t a t i o n s
0.0
0.2
0.4
0.6
0.8
1.0
C u m u l a t i v e F r e q u e n c y o f C i t a t i o n s
0
500
1000
1500
2000
2500
Fig. 1 Representative increase in peer-reviewed publications related to pharmaceuticals in the
environmental through 2010, summarized by the cumulative and relative cumulative citation
frequency of early review papers by Halling-Sorensen et al. [ 15 ], Ternes [ 16 ], and Daughton and
Ternes [ 17 ]. Citation information from Web of Knowledge
http://www.setac.org/node/34http://www.setac.org/node/34http://www.wef.org/http://www.wef.org/http://htpp//www.EmCon2011.comhttp://htpp//www.micropol2011.orghttp://htpp//www.micropol2011.orghttp://htpp//www.EmCon2011.comhttp://www.wef.org/http://www.setac.org/node/34http://www.setac.org/node/34
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4 B.W. Brooks et al.
critically important to now consider the lessons learned from the study of human
pharmaceuticals in the environment and formulate directions for future efforts.
Environmental Analysis and Exposure
To date, the majority of information for human pharmaceuticals in the environment
is related to occurrence in various environmental matrices, which largely accounts
for publication trends summarized in Fig. 1 . Perhaps the most influential paper on
occurrence was published by Kolpin et al. [ 22 ]. In 2002, this landmark article pro-
vided the first national reconnaissance study of a variety of contaminants of emerg-
ing concern, including a number of pharmaceuticals, in water [ 22 ] and promises to
be the most heavily cited paper published in the history of the journal EnvironmentalScience & Technology . In Table 1 , we provide an overview of the representative
literature related to the environmental analysis and occurrence of pharmaceuticals
in the environment. Instead of performing an exhaustive survey and synthesis here,
we instead relay some perspectives on environmental analysis and refer readers to
the recent review of occurrence information for human pharmaceuticals by Monteiro
and Boxall [ 23 ].
Table 1 Representative recent reviews on pharmaceutical analysis in various environmental
matricesTarget analytes Matrix Type of review
Pharmaceuticals Water Analytical methods [ 64 ], multiresidue
methods [ 65 ], LC–MS/MS methods [ 66 ],
basic pharmaceuticals [ 67 ], antibiotics
[ 68 ], anti-inflammatory drugs [ 69 ],
recent advances [ 70 ]
Solidsa LC–MS/MS [ 71 ], tetracycline antibiotics [ 72 ]
Water, solids Analytical methods [ 73 ], LC–MS/MS
methods [ 74 ]
Conventional and/orcontaminants of
emerging concern,
including
pharmaceuticals
Water Analytical methods [ 75, 76 ]Water, solids LC–MS in environmental analysis [ 77 ]
Various environmental
matrices
Analytical methods [ 78, 79 ], methods
applied to fate [ 80 ], environmental mass
spectrometry [ 81 ], recent advances [ 82 ]
Pharmaceuticals
and/or degradation
products
Water Advanced MS techniques [ 83 ], LC–MS
methods [ 84 ], methods applied to fate
and removal [ 85 ]
Various environmental
matrices
Mass spectrometry [ 86 ], analytical problems
and sample preparation [ 87 ]
Other reviews relatedto pharmaceutical
analysis and
general occurrence
information
Multivariate analysis [ 88, 89 ], samplingand/or extraction [ 90– 94 ], chiral analysis
[ 95 ], general occurrence [ 23 ], biological
tissues [ 28, 29, 96 ]
a Sediment, biosolids and soil
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5Perspectives on Human Pharmaceuticals in the Environment
Gas chromatography–mass spectrometry (GC–MS) was the primary analytical
tool used to assess the environmental occurrence of PPCPs in initial studies (Table 1 ).
The popularity of GC–MS in early work was due to its widespread availability and
historical use in contract service laboratories for historical industrial chemical
contaminants. The availability of electron-impact spectral libraries was initially
important, as they increased confidence in analyte identification. Further, the dis-
tinctive nonpolar operating range of GC–MS was consistent with analysis of most
personal care products (PCPs). In contrast, the use of GC–MS for analysis of phar-
maceuticals, which are relatively polar compared to most PCPs, typically requires
derivatization prior to analysis. For example, Brooks et al. [ 3 ] employed GC–MS
with derivatization for initial identification of the antidepressants sertraline and
fluoxetine in fish tissue. However, derivatization reactions are often unpredictable
for complex samples and can limit the quality of quantitative data. Consequently,
liquid chromatography–mass spectrometry (LC–MS) has become the technique ofchoice for analyzing pharmaceuticals in environmental samples.
Numerous studies have demonstrated the distinct advantages of LC–MS for
analysis of pharmaceuticals (Table 1 ). LC–MS enables identification and
quantification without derivatization and typically results in lower detection limits
(below 1 ng/L and 1 ng/g for liquid and solid samples, respectively) and better
precision than comparable GC–MS methodologies. In environmental applications,
LC is typically combined with tandem MS (or MS/MS) to promote enhanced
selectivity and sensitivity for target analytes. In a routine MS/MS analysis, a
molecular ion is selected and subsequently fragmented to produce one or moredistinctive product ions that enable both qualitative and quantitative monitoring.
Recently introduced ultraperformance liquid chromatography (UPLC) provides a
novel approach to chromatographic separation. UPLC differs from regular LC by
the implementation of chromatographic columns with smaller particle diameters
(i.e., sub-2-m m particles), which generates elevated back pressures and narrower
chromatographic peaks. The overall effect is resolved peaks in shorter periods of
time with increased sensitivity. UPLC requires fittings and pumps designed to sup-
port high back pressures, which increases the price of the LC system. An important
feature of UPLC is the need of a fast detector to account for small peak widths(ca. 10 s). In other words to acquire enough data points through chromatographic
peaks, selected mass spectrometer need to collect data points at high sampling
rates. Q-TOF mass spectrometers are often coupled with UPLC systems due to
their fast sampling rates. It is important to note, however, that LC–MS is not exempt
from limitations. One of the limitations of LC–MS is that atmospheric pressure
ionization (API) processes are influenced by coextracted matrix components.
Matrix effects typically result in suppression or less frequent enhancement of ana-
lyte signal. There have been a number of methods proposed to compensate for
matrix effects, including the method of standard addition, surrogate monitoring,and isotope dilution (Table 1 ). Although isotope dilution is the most highly recom-
mended approach for analysis of human pharmaceuticals in environmental matri-
ces, isotopically labeled standards are not always readily available for these target
analytes. A further limitation is the paucity of available isotopically labeled standards
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6 B.W. Brooks et al.
for therapeutic metabolites. An alternative approach involves the use of an
appropriate internal standard (i.e., a structurally similar compound expected to
mimic the behavior of a target analyte(s)) with or without matrix-matched calibra-
tion. However, a given internal standard is typically effective over a limited reten-
tion time window. Accordingly, the use of more than one internal standard is
recommended to compensate for matrix effects throughout the chromatographic
run. Finally, it is important to point out that strategies to compensate for matrix
effects should take into account the variability of matrix within each set of samples
to be analyzed (e.g., surface water, effluent, sediment, fish tissue).
Due to potential regulatory implications of human pharmaceuticals in the envi-
ronment, environmental analyses typically include rigorous quality assurance and
quality control (QA/QC) metrics to confirm reliability of analytical data. Initial
method validation provides essential performance parameters, such as method
recoveries, precision, and limits of detection (LODs). Recurring analysis of qualitycontrol (QC) samples (e.g., method blanks, matrix spikes, laboratory control sam-
ples) is important to verify performance of the method over time, and to assess
potential matrix effects. Considering the unpredictable nature of matrix interference
in LC–MS analysis and the lack of effective strategies to deal with this difficulty, it
has become imperative to use QA/QC data to document and qualify analytical
results for human pharmaceuticals in environmental matrices. This is particularly
important when reporting concentrations at or near the limit of detection for a given
analytical method.
In this volume, an overview of global environmental regulatory activities rele-vant to human pharmaceuticals is provided in Chaps. 2 and 3 . In Chap. 4 , Boxall
and Ericson examine important considerations for understanding the environmental
fate of therapeutics. Below we provide some perspectives on bioaccumulation and
effects of human pharmaceuticals in the environment.
Environmental Bioaccumulation and Effects
Though the potential for uptake of veterinary medicines by animals reared in aqua-
culture were understood for some time (see [ 24, 25 ]), Boxall et al.’s [ 26 ] study of
the uptake of veterinary medicines from soils to plants highlighted the importance
of considering potential accumulation of human medicines in terrestrial organisms
because biosolids and effluents from wastewater treatment plants can be applied
to agricultural fields. Such observations are particularly relevant for antibiotics.
In fact, developing an understanding of the influences of human antibiotics and
antimicrobial agents on antibiotic resistance was recently identified as critical areas
of research need for environmental science and public health [ 21 ].In aquatic systems, Larsson et al. [ 27 ] likely provided the first report of bioac-
cumulation of a human pharmaceutical, 17a -ethinylestradiol, in bile of fish exposed
to Swedish effluent discharges. Brooks et al.’s [ 3 ] findings of the antidepressants
fluoxetine and sertraline (and their primary metabolites) in brain, liver, and muscle
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7Perspectives on Human Pharmaceuticals in the Environment
tissues of three fish species from an effluent-dominated stream (a.k.a. fish on
Prozac) appear to represent the second report in the literature of accumulation of
human pharmaceuticals in wildlife and the first observation from North America.
Such observations stimulated research related to the accumulation and effects of
human pharmaceuticals in the environment and subsequently shaped the National
Pilot Study of PPCPs in Fish Tissue by the US Environmental Protection Agency
[ 28 ] . This study by Ramirez et al. [ 28 ] provided the first evidence of bioaccumula-
tion of a number of human pharmaceuticals in fish collected across a broad geo-
graphic area. A summary of research on bioaccumulation of pharmaceuticals in
aquatic organisms recently highlighted the need to understand thresholds of drug
accumulation associated with adverse effects [ 29 ] . Unfortunately, an understand-
ing of human pharmaceuticals accumulating in terrestrial wildlife is poorly under-
stood [ 20 ] but has been recently identified as a major research question [ 21 ].
Several recent publications have started to further our understanding of the biocon-centration/bioaccumulation potential of pharmaceuticals in a laboratory setting, as
well as publications aimed at understanding pharmaceutical metabolism in wildlife
and its role in the accumulation of drugs [ 30– 39 ] . Below we introduce important
considerations for understanding relationships between pharmaco(toxico)kinetics
and -dynamics of human medications in aquatic and terrestrial organisms. A more
thorough examination of comparative pharmacological approaches for environmental
applications is provided by Gunnarsson et al. in Chap. 5.
Understanding the environmental risks posed by historical contaminants has
been challenged by the paucity of toxicity information available for most industrialchemicals [ 40 ]. In the case of human pharmaceuticals, however, intensive investiga-
tions occur prior to distribution, which yields a wealth of pharmacological and toxi-
cological data compared to other industrial contaminants. To illustrate available
data, Table 2 provides a summary of common characteristics for hundreds of phar-
maceuticals. During the design of therapeutics, careful consideration is given to
target-specific biomolecules (e.g., receptors, enzymes) and pathways to elicit
beneficial outcomes. Because side effects are not desirable and large margins of
safety (relationship between therapeutic and toxic doses) are ideal, pharmaceutical
development often results in therapeutics with relative well-understood mecha-nisms/modes of actions (MOAs) and very low acute toxicity in mammals. For
example, a recent study predicted that less than 8% of all pharmaceuticals are
expected to be classified as highly acutely toxic to rodent models [ 41 ]. Similarly,
Berninger and Brooks [ 41 ] predicted that less than 6% of all pharmaceuticals are
acutely toxicity to fish below 1 mg/L.
As noted previously, concentrations of individual human pharmaceuticals in
surface water of developed countries rarely exceed parts per billion levels; thus,
limited acute toxicity is expected in surface waters of the developed world.
Unfortunately, most studies to date have only examined acute toxicity in standardaquatic organisms [ 42 ] . However, chronic adverse responses resulting from thera-
peutic MOAs are more likely to be observed in the environment [ 41 ] , particularly
in systems with instream flows dominated by continuous release of effluent dis-
charges [ 43 ] leading to longer effective exposure durations [ 11 ]. Early investigators
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8 B.W. Brooks et al.
T a b l e 2
A s u m m a r y o f t h e m i n i m u m a n d m
a x i m u m v a l u e s a n d 1 0 t h ,
5 0 t h , a
n d 9 0 t h c e n t i l e s o f c o m m o n p r o p e r t i e s a s s o c i a t e d w i t h p h a r m a c e u t i c a l s
M W
l o g
P
L D
5 0
C m a x
A T R
C l
T ½
V d
A q E T
M i n
6 . 9
4
− 9 . 4
0 . 0
0 0 7 5
7 . 5 × 1 0
− 6
1 . 6
0 . 0
0 2 9
0 . 0
3 3
0 . 0
3 5
8 . 4 × 1 0 −
1 0
C e n t i l e s
1 0 t h
1 6 4
− 0 . 9
5
7 7
0 . 0
0 1 7
9 7
0 . 4
9
0 . 7
7
0 . 1
5
2 . 9 × 1 0 −
5
5 0 t h
3 4 6
2 . 0
3
9 7 1
0 . 1
3 0 0
8 , 1
2 7
3 . 7
1
5 . 0
1
1 . 0
3
0 . 0
4 4 6
9 0 t h
7 3 2
5 . 0
1
1 2 , 2
8 3
9 . 9
1
6 8 1 , 6
5 7
2 7 . 9
3 2 . 6
6 . 9
6
6 9 . 4
M a x
1 4 5 , 7
8 1
8 . 6
5 6 , 0
0 0
3 3 0
4 . 7 × 1 0 8
1 , 0
7 0
8 7 , 6
0 0
2 , 3
4 8
9 . 1 × 1 0 9
n
1 , 0
4 2
7 9 7
1 , 0
3 5
8 3 2
7 4 1
9 3 6
9 7 9
9 4 4
8 3 1
M W m o l e c u l a r w e i g h t ( g / m o l ) ; l o g P o c t a n o l
– w a t e r p a r t i t i o n i n g c o e f fi c i e n t ; L
D 5
0 m e d i a n o r a l l e t h a l d o s e f o r r a t m o d e l ( m g / k g ) ; C
m a x
h u m a n p
e a k p l a s m a
c o n c e n t r a t i o n ( o r t h e r a p e u t i c d o s e ; m g
/ m L ) ; A T R a c u t e t o t h e r a p e u t i c r a t i o m a r g i n o f s a f e t y a n a l o g ( L D
5 0
/ C m a
x ; s e e B e r n i n g e r a n d B r o o k s [ 4 1 ] ) ; C l c l e a r -
a n c e r a t e ( m
g / m i n / k g ) ; T
½ h
a l f - l i f e o f e l i m i n a t i o n ( h o u r ) ; V
d a p p a r e n t v o l u m e o f d i s t r i b u t i o n ( L / k g ) ; A q E T i s
t h e a q u e o u s e f f e c t t h r e s h o l d ( m
g / L ) w h e r e
fi s h p l a s m a B C F / C
m a x
= a q u a t i c e x p o s u r e c o n c e n t r a t i o n a t t h e p o i n t i n w h i c h C
m a x
= fi s h p l a s m a c o n c e n t r a t i o n a n d fi s h p l a s m a B C F × e
x p o s u r e
c o n c e n t r a -
t i o n = fi s h p l a s m a c o n c e n t r a t i o n [ 2 9 ]
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9Perspectives on Human Pharmaceuticals in the Environment
recognized the importance of leveraging mammalian pharmacological safety data
to help understand various pharmaceutical effects in the environment, because
many MOAs of human therapeutics appear to be evolutionarily conserved, particularly
in vertebrates [ 14, 44– 46 ].
In 2003, Huggett et al. [ 47 ] proposed a screening approach to identify pharma-
ceuticals in water that may result in fish plasma levels (or internal doses)³ human
therapeutic levels (e.g., C max
). Huggett’s plasma model was based on three core
assumptions: (1) Evolutionary conservation of structure and function of drug targets
among mammals and fish species; (2) Internal fish doses approaching mammalian
C max
levels would result in similar therapeutic outcomes; and (3) A gill uptake model
[ 48 ] for predicting rainbow trout plasma concentrations following waterborne expo-
sure to nonionizable chemicals [ 48 ]. Subsequently, several recent studies have
employed the Huggett et al. plasma model approach [ 49– 51 ] or conceptually similar
variations to account for ionization influences on bioavailability [ 29, 52, 53 ]. Ofparticular importance, Valenti et al. [ 53 ] recently provided an independent valida-
tion of the Huggett et al. [ 47 ] plasma model when ionization of the weak base ser-
traline [ 54 ] and an alternative gill uptake model [ 48 ] was considered. Valenti et al.
[ 53 ] also employed an adverse outcome pathway (AOP) design [ 55 ], which included
quantification of binding at the therapeutic target and anxiety-related behavioral
responses stereotypical of the therapeutic efficacy of this model antidepressant. In
the Valenti et al. [ 53 ] study, adult male fathead minnow were exposed via aqueous
exposure to sertraline for 21 days. Fish plasma concentrations were accurately pre-
dicted from water exposures when pH influences on ionization and lipophilicitywere considered [ 29, 52, 54 ]. When these plasma levels in fish exceeded the human
therapeutic dose (C max
) of sertraline, binding to the serotonin reuptake transporter
and antianxiety behavior were significantly affected [ 53 ]. The AOP approach was
recently proposed by Ankley et al. [ 55 ] for linking molecular initiation events, such
as those related to pharmaceutical interactions with a target site (e.g., a receptor),
with cascading events leading to adverse outcomes at the individual and population
level, which can be used as measures of effect in risk assessments. As demonstrated
by Valenti et al. [ 53 ], linking predictions of uptake from surface waters to fish
plasma with conceptual AOP models appear to represent a sound foundation fromwhich potentially hazardous human pharmaceuticals may be identified.
Probabilistic hazard assessment approaches, which are commonly used to sup-
port environmental and public health decision making, can use existing mammalian
pharmacological safety data to develop predictive models for various parameters
[ 41 ]. These predictive tools can support prioritization activities for testing hypoth-
eses regarding pharmacological parameters of various drug classes or chemical
specific computational attributes that may result in hazards to wildlife [ 41 ]. For
example, Table 2 presents the minimum and maximum values and 10th, 50th and
90th centiles of probabilistic pharmaceutical distributions (PPD) of molecularweight, logP, acute LD
50 , C
max , acute to therapeutic ratio margin of safety analog
(LD50
/C max
; see [ 41 ]), clearance rate, half-life of elimination, apparent volume of
distribution (V d ), and the aqueous effect threshold (AqET; see [ 52 ]) based on data
from hundreds of pharmaceuticals. PPD approaches can be used to predict the
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10 B.W. Brooks et al.
likelihood of encountering another therapeutic with attributes of interest. To illus-
trate the utility of PPD analyses, Fig. 2 depicts a PPD for V d . Briefly, V
d data were
ranked and converted to probability percentages then plotted against respective
probability ranks on a log-probability scale; centiles were determined by regression
(see [ 30 ] for a complete description of methods). Using this approach, we predict
that 10% or less of all pharmaceuticals would have V d values of 0.15 L/kg. In Fig. 3 ,
we extend the PPD assessment to predict the likelihood of encountering a pharma-
ceutical in surface waters exceeding the AqET value, which is based here on the
specific assumptions of Huggett et al.’s [ 47 ] plasma model. For example, 10% of allpharmaceuticals are predicted to result in internal fish plasma concentrations equal-
ing the human C max
value at or below an environmentally relevant surface water
concentration of 29 ng/L (Fig. 3 , Table 2 ).
Based on the current state of the science, it appears critical to develop an advanced
understanding of the risks associated with human pharmaceuticals in the environ-
ment. In Chaps. 6 and 7 , Lattier et al. consider mechanistic characteristics of drugs
for reconstructing environmental exposure scenarios and Brain and Brooks provide
perspectives for incorporating non-standard endpoints in environmental risk assess-
ments, respectively. In Chap. 8 , Williams and Brooks examine human health riskassessment considerations for environmental exposures to therapeutics. When the
outcome of an environmental risk assessment identifies unacceptable risks to wildlife
or humans, risk management decisions and practices serve as interventions to
protect public health and the environment. In the case of pharmaceuticals and other
Apparent Volume of Distribution (L/kg)
10-3 10-2 10-1 100 101 102 103 104
P e r c e n t R a n k
0.01
0.1
1
10
30
50
70
90
99
99.9
99.99
Fig. 2 Probabilistic pharmaceutical distribution of apparent volume of distribution (L/kg) for 944
pharmaceuticals. Reference lines relate to the 10th, 50th and 90th centiles (Table 2 ), which corre-
spond to 0.15, 1.03, and 6.96 L/kg, respectively. For example, apparent volume of distribution is
predicted by this model to be at or above 6.96 L/kg for 10% of all pharmaceuticals
http://dx.doi.org/10.1007/978-1-4614-3473-3_6http://dx.doi.org/10.1007/978-1-4614-3473-3_7http://dx.doi.org/10.1007/978-1-4614-3473-3_8http://dx.doi.org/10.1007/978-1-4614-3473-3_8http://dx.doi.org/10.1007/978-1-4614-3473-3_7http://dx.doi.org/10.1007/978-1-4614-3473-3_6
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11Perspectives on Human Pharmaceuticals in the Environment
contaminants in treated wastewater effluents, a number of treatment approaches,
including appropriately designed and maintained constructed wetlands [ 56 ], appear
viable for supporting risk management of indirect and direct potable water reuse.
In this volume, Chaps. 9 and 10 examine timely issues related to environmental risk
management. In Chap. 9 , Gerrity and Snyder examine the available information
related to the efficacy of various wastewater and drinking water treatment technolo-
gies for human pharmaceuticals. In Chap. 10 , Stoddard and Huggett conclude this
volume with an interesting perspective on pharmaceutical take back programs,which promise to divert unused medications from down the drain discharges and
drug abuse by and poisonings of unintended users.
Lessons learned from human pharmaceuticals in the environment will continue to
advance our understanding of the environmental risks of chemicals. For example, a
number of organic contaminants are chiral, which remains an important environmental
consideration because fate and effects often differ among enantiomers [ 57 ]. Herein,
studies of chiral pharmaceuticals have advanced our understanding of risks posed by
other chiral chemicals [ 58 ]. Similarly, many environmental contaminants, including
metabolites and degradates, are weak acids and weak bases. Because site-specific pHinfluences environmental fate, uptake and toxicity, the study of ionizable therapeutics
(~70% of all drugs are weak bases) has advanced our understandings of the impacts of
climatic changes on bioaccumulation and toxicity of moderately polar and ionizable
chemicals [ 59, 60 ]. Interestingly, lessons learned from the study and design of less-toxic
Aqueous Effect Threshold (mg/L)
10-11 10-9 10-7 10-5 10-3 10-1 101 103 105 107 109
P e r c e n t R a n k
0.01
0.1
1
10
30
50
70
90
99
99.9
99.99
Fig. 3 Probabilistic pharmaceutical distribution of aqueous effect threshold (AqET; mg/L) for 831
pharmaceuticals. Reference lines relate to the 10th, 50th, and 90th centiles (Table 2 ), which cor-
respond to 29 ng/L, 44.6 m g/L, and 66.4 mg/L, respectively. For example, an aquatic concentration
leading to a plasma concentration in fish above the mammalian C max
value is predicted by the
AqET model to be at or below 29 ng/L for 10% of all pharmaceuticals
http://dx.doi.org/10.1007/978-1-4614-3473-3_9http://dx.doi.org/10.1007/978-1-4614-3473-3_10http://dx.doi.org/10.1007/978-1-4614-3473-3_9http://dx.doi.org/10.1007/978-1-4614-3473-3_10http://dx.doi.org/10.1007/978-1-4614-3473-3_10http://dx.doi.org/10.1007/978-1-4614-3473-3_9http://dx.doi.org/10.1007/978-1-4614-3473-3_10http://dx.doi.org/10.1007/978-1-4614-3473-3_9
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12 B.W. Brooks et al.
pharmaceuticals, often described as benign by design [ 61 ], can be extended to advance
green chemistry principles by developing sustainable molecular design guidelines for
reducing the toxicity of other industrial contaminants [ 62, 63 ]. To the fields of aquatic
toxicology and environmental risk assessment in particular, understanding the toxicity
of human pharmaceuticals in the environment is beginning to advance our understand-
ing of toxicity pathways. To date, relatively few toxicity pathways have been defined in
ecological systems, but hundreds of pharmaceuticals targets are evolutionarily con-
served across the various kingdoms. Developing an understanding of pharmaceutical
MOAs and associated AOPs will improve prospective and retrospective diagnosis and
management of environmental risks posed by industrial contaminants. Clearly a num-
ber of timely research questions remain unanswered [ 21 ].
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waste water, sediment and sludge. Anal Chim Acta 593:129–139
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77. Hao C, Zhao X, Yang P (2007) GC-MS and HPLC-MS analysis of bioactive pharmaceuticals
and personal-care products in environmental matrices. Trends Anal Chem 26:569–580
78. Morley MC, Snow DD, Cecrle C, Denning P, Miller L (2006) Emerging chemicals and analyti-
cal methods. Water Environ Res 78:1017–1053
79. Kot-Wasik A, Debska J, Namiesnik J (2007) Analytical techniques in studies of the environ-
mental fate of pharmaceuticals and personal-care products. Trends Anal Chem 26:557–568
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17B.W. Brooks and D.B. Huggett (eds.), Human Pharmaceuticals in the Environment:Current and Future Perspectives, Emerging Topics in Ecotoxicology 4,DOI 10.1007/978-1-4614-3473-3_2, © Springer Science+Business Media, LLC 2012
Introduction
An overview is given on environmental risk assessment for pharmaceuticals (ERA),with a description of the current regulatory requirements for human pharmaceuti-cals ERA in Europe and the USA as well as developments worldwide. In addition,further developments on national levels concerning the environmental safety ofpharmaceuticals are presented. Also, a short comparison with international veteri-nary pharmaceuticals guidelines and with biocides ERA is given.
As long as human population density is low and excreta are spread diffusely overa large area, no significant levels of PAS or metabolites are expected in the environ-ment. But when population density increases, when excreta collect in sewage andthe latter is discharged, after wastewater treatment or not, to receiving waters, mea-surable to significant concentrations in surface waters may be reached. With strongpopulation growth in industrialised societies from the nineteenth century onward,with sewage collection systems in the growing cities and with the increase in thenumber of pharmaceutical companies and their biologically active products, a risein environmental concentrations of at least certain PAS followed during the pastcentury. A parallel development in analytical methods and power, expressed asconstantly decreasing limits of detection and quantitation, inevitably led to determi-nations of PAS in environmental matrices.
J.O. Straub (*) F.Hoffmann-La Roche Ltd, Group SHE,LSM 49/2.033, Basle CH-4070, Switzerland
e-mail: [email protected]. HutchinsonCEFAS Weymouth Laboratory, Centre for Environment, Fisheries and Aquaculture Sciences,The Nothe, Barrack Road, Weymouth, Dorset DT4 8UB, UKe-mail: [email protected]
Environmental Risk Assessment for Human
Pharmaceuticals: The Current State
of International Regulations
Jürg Oliver Straub and Thomas H. Hutchinson
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18 J.O. Straub and T.H. Hutchinson
The first analytical detections of PAS and metabolites in environmental mediaare reported from the USA in the 1970s [ 33, 37 ], where among others salicylicacid, the main metabolite of acetylsalicylic acid was detected in sewage workseffluent. These initial detections initiated a rapidly growing list of similar publica-tions and reviews covering sewage treatment effluent, surface, estuarine, marine,ground and tap water over the following decades (e.g. Richardson and Bowron[ 64 ] , Aherne and Briggs [ 1 ], Ayscough et al. [ 4 ] and Thomas and Hilton [ 77 ] in theUK; Heberer et al. [ 35 ] and Ternes et al. [ 73 ] in Germany; Halling-Sørensen et al.[ 34 ] in Denmark; Buser et al. [ 10 ] and Tixier et al. [ 77 ] in Switzerland; Belfroidet al. [ 6 ] in the Netherlands; Stumpf et al. [ 72 ] in Brazil; Zuccato et al. [ 84 ] andCalamari et al. [ 11 ] in Italy; Farré et al. [ 28 ] and Fernández et al. [ 29 ] in Spain;Kolpin et al. [ 48 ] and Barnes et al. [ 5 ] in the USA; Metcalfe et al. [ 54 ] in Canada;Vieno et al. [ 81 ] in Finland; Nakada et al. [ 57 ] in Japan; Rabiet et al. [ 63 ] in France;
Kim et al. [ 47 ] in South Korea). Note this is not meant to be a complete list butrather an illustration of the worldwide increase in publications in the 1990s and2000s. Again, the scope of detections widened with massively refined analyticalinstruments and methods.
In parallel to these ubiquitous detections in environmental media, the question ofpossible adverse effects caused by PAS to environmental organisms and ecosystemsalso gained importance. Initial environmental risk assessments (ERAs), comparingenvironmental concentrations with known effects, began in the 1980s. The concernsabout environmental safety of PAS, alone and in particular in combinations, strongly
increased with accruing evidence for widespread endocrine disruption in wild fish[ 44 ], in particular downstream of sewage treatment works effluents and also withexperimental adverse effects seen with a few PAS at very low concentrations (e.g.[ 19, 30, 43 ]), which in some cases were close to or within the range of measuredenvironmental concentrations (MECs). In parallel, the use of PAS or similar sub-stances has played an important role in other areas of aquatic research, includingaquaculture [ 31, 40 ] and marine antifoulant paints [ 38, 50, 61 ].
In view of mounting evidence for widespread environmental exposure and poten-tial or probable environmental effects of PAS, enquiries and investigations into
environmental hazards and risks due to PAS began in the 1980s (e.g. [ 1, 18, 34, 36, 46, 65, 78 ]). In parallel to these often government-sponsored investigations, thenecessity for and development of formal ERAs specifically for PAS (pharmaceuti-cals ERA or PERA) was recognised by regulators on both sides of the Atlantic,which led to legal requirements and, with some delay, to guidelines for such PERAsas part of the registration dossier from the 1990s onwards. Formal guidelines weredeveloped and published in 1998 in the USA and in 2006 in the European Union(EU). In other countries, PERAs are requested (e.g. Australia) or formal own guidelinesare in the making (Canada, Japan). In addition, Sweden led the way with a system
for the ERA of “old” PAS already on the market. But even beyond the formalrequirements for PERAs in the context of registration, PAS in the environment (PIE)may be the subject of other legislation than registration, which, however, may stillrequire some kind of ERA. These developments and current states will be outlined inthe following paragraphs.
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19Current State of Regulations for Human Pharmaceuticals ERA
Current State of PERA Regulation in Various
Regions or Countries
PERA started in the USA and EU in the 1980s or early 1990s. Much of the method-ology seems to derive from pesticides ERA, which came into focus and developedappropriate methodologies earlier than pharmaceuticals in general. All of the ERAprocedures have in common a comparison between predicted (or measured) environ-mental concentrations (PECs or MECs) with predicted no effect concentrations(PNECs), both per environmental compartment under consideration. Such compart-ments may be wastewater treatment, surface waters, sediments, groundwaters, tidaland coastal/marine waters, soils (through landspreading of surplus sewage sludge,called biosolids in North American terminology) and, rarely, the atmosphere. PECs
are derived from either predicted use or maximum daily use multiplied by a defaultuse or penetration factor in the population, integrating human metabolism and deple-tion during sewage treatment or in the environment, sorption and distribution to otherenvironmental compartments, dilution and advection (off-transport by the medium) inthe receiving compartments. PNECs are mostly derived from either acute or chronicecotoxicity tests, normally with standard organism groups representative for the com-partment, by dividing by assessment factors (AFs) which are dependent on the char-acter and number of ecotoxicity results available. In higher tiers of the ERA, the abovedeterministic procedure using AFs can be replaced by probabilistic methodology,
where the distributional characteristics of a number of ecotoxicity test results(normally at least ten chronic datapoints) are used to derive a PNEC. PECs and PNECsare compared per compartment, in general through forming the PEC/PNEC ratio.If this ratio is
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20 J.O. Straub and T.H. Hutchinson
assessments (EAs in US legal terminology) within the US Food and Drugs legislation(21 CFR 25; current version available at http://www.accessdata.fda.gov/scripts/cdrh/ cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25 ). By this, “all applications or petitionsrequesting Agency action must be accompanied by either an EA or a claim of categor-ical exclusion; failure to submit one or the other is sufficient grounds for refusing tofile or approve the application” (cited from “Environmental Impact Review at CDER”,http://www.fda.gov/AboutFDA/CentersOf fices/CDER/ucm088969.html). In 1998 theUS Center for Drug Evaluation and Research (CDER) and the Center for BiologicsEvaluation and Research (CBER) within the US Food and Drug Administration pub-lished a “Guidance for Industry, Environmental Assessment of Human Drug andBiologics Applications”, revision 1 [ 14 ], which is still current today.
The Guidance describes in which cases an EA can be waived and how to proceedwith an EA in the remainder. Waivers, the so-called categorical exclusions, may be
invoked in the following cases:
If the application does not increase the use of active moiety (i.e. in case of exten-•sions or additional applications by third parties for PAS already on the market).If the application may lead to increased use but the estimated concentration of•the AS at the point of entry into the environment is less than 1 part per billion(ppb). This means that the entry into the environment concentration (EIC) of aparticular PAS from US publicly owned treatment works (POTWs) must bebelow 1 m g/L, discounting all metabolism; calculating back from an EIC of
1m
g/L and the average annual total effluent of all POTWs results in a maximumannual amount of approximately 44 metric tonnes of PAS per year for the wholecontinental USA, based on daily POTW inflow data given in the Guidance ([ 14 ];p 4). Hence, if the predicted annual use of a new PAS is below 44 tonnes/annumthere is no need for an EA, except if the applicant has information to suggest thatthe use of even a lesser quantity may “significantly affect the quality of thehuman environment” ([ 14 ]; p 3).For biological PAS if their use will not lead to significant concentrations in the•environment.For investigational new drugs still under development in clinical research.•For specific biological products for blood or plasma transfusion.•
In all other cases, the applicant needs to prepare an EA following a tiered, step-wise approach that follows the course of a PAS from human excretion into theenvironment. Hence, in a first basic step , if there is experimental evidence that anew PAS is rapidly depleted, e.g. through biodegradation in a POTW, and not inhib-itory to microorganisms, the EA can be stopped and finalised with a Finding of NoSignificant Impact (FONSI). If the PAS is not rapidly depleted and if it is lipophilic(with an n -octanol/water distribution coefficient logD
OW ³ 3.5 at a relevant environ-
mental pH of approximately 7), suggesting bioaccumulation, the applicant shouldinitiate chronic testing in tier 3; note the tier numbering is given according to theGuidance [ 14 ]. Further details as to depletion (degradation, hydrolysis or parti-tioning to other environmental compartments) and to interpretation of these fateprocesses are given.
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25http://www.fda.gov/AboutFDA/CentersOffices/CDER/ucm088969.htmlhttp://www.fda.gov/AboutFDA/CentersOffices/CDER/ucm088969.htmlhttp://www.fda.gov/AboutFDA/CentersOffices/CDER/ucm088969.htmlhttp://www.fda.gov/AboutFDA/CentersOffices/CDER/ucm088969.htmlhttp://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=25
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21Current State of Regulations for Human Pharmaceuticals ERA
In all other cases, the effects testing starts with one acute test in tier 1. If the ratioof the 50% effect or 50% lethal concentration (EC50 or LC50) in this test dividedby the EIC or predicted (or expected in US terminology) environmental concentra-tion (PEC or EEC), whichever is higher, is ³ 1,000 and there were no adverse effectsobserved at the higher of EIC or EEC (termed maximum expected environmentalconcentration or MEEC), the EA can be stopped and finalised. This ratio corre-sponds to a margin of safety (MOS) in general ERA terminology. If there wereeffects at MEEC, the applicant should initiate chronic testing in tier 3.
If the tier 1 MOS is
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22 J.O. Straub and T.H. Hutchinson
(e.g. [ 55 ], for Delaware drinking waters). Within half a year starting from the firstAP report, according to the AP [ 3 ] site, a US Congressional Panel discussed moni-toring and potential impacts of micropollutants including PAS in environmentalwaters, which are currently not regulated by the US Environmental ProtectionAgency (EPA) either as a group or as single substances in the USA. The discussionseemed to focus mainly on potential human risks from PIE through water abstrac-tion, treatment and consumption as drinking water, but less on risks for environmen-tal organisms or ecosystems. Also, questions on PIE and the safety of PAS indrinking waters were raised in the US Senate Committee on Environment and PublicWorks ( http://epw.senate.gov/public/index.cfm , search for “pharmaceuticals” and“water”). Some investigations on potential human health risks from PIE via drink-ing water were published in the previous decade (e.g. [ 9, 12, 16, 17, 45, 67, 83, 84 ]),all of which have found no significant risks based on the available evidence.
In addition, on July 7, 2010, the Great Lakes Environmental Law Center and theNatural Resources Defense Council as petitioners submitted a “Citizen Petition” tothe US Food and Drugs Administration Commissioner. A Citizen Petition in the USis a legal means to challenge existing regulations. In this Citizen Petition concerningan amendment to the current US PERA Guidance [ 14 ], the repealing of the categori-cal exclusion threshold of 1 ppt (1 m g/L, corresponding to approximately 44 metrictonnes of PAS per annum) EIC is requested, “because the current regulation doesnot reflect a safe standard supported by current scientific information”. In case thethreshold for a categorical exclusion is indeed repealed, this would mean that nearly
all new human PAS would need an EA for registration.It will remain to be seen whether the parliamentary discussions and legal motions
in the USA will eventually have effects on US regulations, on PERA in general, onthe US PERA Guideline, possibly also for “old” PAS already on the market, or forthe regulation of water contaminants by the EPA.
PERA in the European Union
First requirements for PERA were laid down in EU Directive 93/39/EEC, whichasked to “give indications of any potential risks presented by the medicinal productto the environment”. The development of the PERA guideline in the EU took 13years in all, with several draft guidelines published during that time [ 68, 69 ]. In2006, the European Medicines Agency (EMA, London, UK; note that the formerabbreviation EMEA for European Medicines Evaluation Agency is not being usedany longer) published the first definitive Guideline for Environmental RiskAssessment of Human Medicines [ 26 ]. This guideline describes a tiered procedure,
from categorical exclusion or direct referral, to a simple, worst-case exposure esti-mation of a pharmaceutical active substance to the investigation of fate and effectsin sewage works and surface waters, up to a refined assessment for these or otherenvironmental compartments.
http://epw.senate.gov/public/index.cfmhttp://epw.senate.gov/public/index.cfmhttp://epw.senate.gov/public/index.cfm
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23Current State of Regulations for Human Pharmaceuticals ERA
A PERA is required for new registrations (Medicines AuthorisationApplication or MAA in EU terminology) and for all repeat registrations by thesame applicant, termed “variations” in the EU, that may lead to significantlyincreased environmental exposure to the PAS; note that “significant” is notdefined or quantified in this context. In the basic Phase 1 of the PERA, certaincategories of PAS are excluded from PERA (amino acids, proteins, peptides,carbohydrates, lipids, electrolytes, vaccines and herbal medicines), while otherPAS are directly referred to special ERA. Highly lipophilic PAS with a log K
OW
> 4.5 are directly referred to a persistence, bioaccumulation a